Three insurer trade organizations have sent a joint letter to the Secretary of Health and Human Services, Kathleen Sebelius, seeking to extend the April 1, 2010 implementation of the Medicare Secondary Payer (MSP) mandatory insurer reporting (MIR) requirement. This letter outlines five major reasons as to why the Department of Health and Human Services should consider extending the deadline:
- Reporting Guidance: the Centers for Medicare and Medicaid Services (CMS) has yet to issue final guidance on some issues.
- Collection of Social Security Numbers (SSN) or Health Insurance Claim Numbers (HICN): insurance and self-insured companies are concerned about the inability to obtain critical data elements such as SSNs or HICNs.
- Confidentiality and Security of the Data: there are still serious concerns that the CMS is not using the most effective security and encryption technology to ensure the data submitted is properly secured.
- Inadequate testing period: there are concerns that the testing period CMS used was too short for required reporting entities (RREs) and CMS to properly ensure that their systems were operational prior to the reporting deadline.
- Penalties: there is a belief that the $1000 per day, per claim penalty is excessive. There is further belief that this penalty should not be enforced on the initial reports submitted by RREs.
If successful, this would represent the third extension since Section 111 of the Medicare, Medicaid, SCHIP Extension Act of 2007 (MMSEA) first called for MIR compliance.
To read the letter in its entirety, please click here.